Daimler Truck North America LLC Privacy Statement

Updated: February 7th, 2022

(Consumers residing in California also should consult the California Supplement to the Privacy Statement)

Daimler Truck North America LLC and its affiliates (“DTNA”) appreciate your interest in their products and services and your visit to their internet sites, Daimlertrucknorthamerica.com and other DTNA sites that link to this Privacy Statement (the “Sites”). Your privacy is important to us and we want you to feel comfortable visiting our Sites and using our products and services. Protecting your privacy in the processing of your personal data is an important concern to which we pay special attention. This online privacy statement tells you about the information that DTNA may collect from you through the Sites and through your use of our products and services, how we use that information, and how you can opt out of certain uses of information we may collect. Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. If you do not agree with our policies and practices, your choice is not to use our Sites, our products or our services. By using our services and accessing our Sites, you are consenting to the information collection and use practices described in this online privacy statement, as modified from time to time by us. If we decide to change this online privacy statement, we will post a new online privacy statement on our Sites and change the date at the top of the online privacy statement. Therefore, we encourage you to check the date of our online privacy statement whenever you visit any of our Sites for any updates or changes. Your continued use of DTNA’s Sites, our products and services after we make changes is deemed acceptance of those changes. Our online privacy statement complies with the Daimler Truck AG Data Protection Code of Conduct applicable company-wide for Daimler Truck AG. Our Sites may include, however, links to other websites which are not covered by this online privacy statement. These sites have their own privacy and information security policies and terms and conditions. Please review the privacy policy and terms and conditions sections of such websites for additional details.


DTNA Services
If you are a customer utilizing DTNA’s services, including its Dealer Portal and Detroit Connect service, you may load electronic data into these services and DTNA may upload data collected from your vehicle for your use through the services (“Customer Data”). DTNA will not share or distribute any Customer Data except as provided for in the agreement between DTNA and the customer, or as required by applicable law. The use of information collected through DTNA services is limited to the purpose of providing the service requested by the customer, including the improvement of services and products, and the development of new services and products. DTNA may use, access, and process information in order to provide the service, respond to support requests, prevent or address technical issues, carry out customer instructions, or comply with applicable law, in accordance with the relevant agreement between customer and DTNA.

DTNA processes Customer Data under the direction of its Customers, and DTNA has no direct control or ownership of personal data provided by Customers. Customers are responsible for complying with any laws and regulations that require obtaining consent or providing notice and disclosure before sharing any data with DTNA.

If you are a user of any services provided by DTNA on behalf of a customer, your use of the services is governed by the rules and policies set by your organization. Please direct your concerns or privacy related questions to your employer. DTNA will forward all requests for the disclosure of Personal Information made by law enforcement or government officials to its customers unless otherwise required by law.

DTNA’s Use and Collection of Information
Information That We Collect
Some features of the DTNA Sites and services may ask you to provide us with specific categories of information in order to enjoy complete functionality. If you do not provide us with the categories of information requested, your ability to fully interact with the DTNA Sites and services may be limited. Please note that there may be other uses, which we would describe to you when we collect that information.

DTNA uses the information we collect about you to provide you with DTNA websites, services, and support. For example, if you provide information to us in a “Contact Us” form, we will use your information to respond to the request and communicate with you. DTNA may use the contact information we collect from you and information about your activity on our websites to send you information that we believe may be of interest to you, such as product announcements, newsletters, educational materials, details on upcoming events and other marketing communications. We also use it to send administrative information, such as notices related to products, services, or policy changes.
We use certain third-party web analytics services, such as Google Analytics, to help understand how our websites and services are being used and to make improvements. Your information also may be used to personalize your experience on our websites.

DTNA or our service providers use website tracking technologies to display products or features that are tailored to your interests. For more information on managing your choices in relation to cookies, you may visit the Cookies section of this Statement.

We may use your information to diagnose website technical problems, as well as to prevent, detect, mitigate, and investigate potential security issues, as well as fraudulent or illegal activity.

In some instances, we may combine the information you have provided to us with other publicly available information. We may also purchase data from third parties and combine this with information we have already collected. We use this combined information to update, expand, and analyze our marketing leads; identify new customers; and create more tailored advertising.
Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Similar to other websites, our Sites are not designed to respond to “Do Not Track” signals received from browsers.

DTNA will retain your Personal Information only as long as needed to provide you with the services or as necessary to comply with legal obligations, enforce agreements, or to resolve disputes. Data collected pursuant to a service is retained in accordance with the terms of the agreement for that service.

Some specific features that require you to provide information to DTNA are described in detail below:

Surveys
You may be asked to participate in surveys about your experience with the DTNA Platform. When participating in surveys, any information you provide in the comments field will be shared with us, so please do not include any sensitive Personal Information or other information you do not wish to share.

Placing an Order
When you place an order for parts, reserve a vehicle, or purchase other items using the DTNA Sites or services, you are required to provide information necessary to fulfill that order or secure your deposit, including your name, address, phone number, and payment information. We use a third-party service to process orders, deposits, and payments. For more information, please review the “Information Sharing” section of this Privacy Statement.

Account Registration
When you register for an account with our Sites or services, you must provide your name and email address. You also have the option to allow DTNA to contact you with information about products or services that may be of interest to you. Once your account is established, you have the option to provide us with additional information such as your address and phone number. You will also have the ability to save vehicle configurations and fleet information in your account. We store that information for as long as your account is active. You may modify your accounts at any time by visiting the “Profile” settings and making changes to individual fields.

Information Collected from Third Parties
We also obtain information about the traffic and usage of DTNA Sites and services from third parties such as Google. These third parties also use cookies and other tracking technologies to capture information about your interactions with the DTNA Sites and services. DTNA does not have control over the information that is collected, used, and shared by these third parties, though DTNA may combine this information with information you provide to us. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

Information Sharing
DTNA may share information with its affiliates, and third party service providers or vendors that DTNA contracts with in order to provide services on your behalf. These third party service providers and vendors may use information we provide them only as instructed by DTNA.

Placing an Order
We use a third party service provider to manage our purchase order website and to manage payments when you make purchases. Information you provide when making online purchases is shared with our third party service providers so that your payment can be processed and your order can be fulfilled.

Aside from the instances described above, we will only share your Personal Information: to comply with the law; to respond to claims; to comply with legal process served on DTNA, its affiliates, subsidiaries, or our parent company Daimler Truck AG (e.g., a lawful subpoena, warrant, or court order); to enforce or apply our policies or agreements; (including to bill and collect payments); to protect and defend our rights or property or that of our dealers, customers, employees, visitors, or the public; in connection with a business transfer, sale, liquidation, or merger; and if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; with your consent.

Children’s Online Privacy Protection Act (COPPA)
The DTNA Sites and services are neither designed for nor targeted to children under the age of 13. If you are under the age of 13, do not provide your Personal Information through the DTNA Sites or services. If you believe your child has impermissibly provided us with their Personal Information, please contact us, so that we can identify and delete their information.

Security
We use commercially reasonable administrative, technical, and physical safeguards to protect Personal Information collected through the DTNA Sites and services.

Contact Us
If you have comments, questions, or concerns about this Privacy Statement or about DTNA’s collection, use, or disclosure of your Personal Information, or if you would like to make a request to review or update your Personal Information, please contact us.

Email: DTNAprivacy@daimlertruck.com
Phone: 1-800-331-0807
Mailing Address:
Daimler Truck North America LLC
4555 N. Channel Ave
Portland, OR 97217

Updates
DTNA may update or change this Privacy Statement from time to time and without prior notice to you. The top of this Privacy Statement will indicate when it was most recently updated.

Links to Other Websites
Please be aware that we provide links to third-party sites as a service to our visitors, and that we are not responsible for the content or information collection practices of those sites. We encourage you to review and understand their privacy practices before providing them with information.

Privacy Statement Revisions
A revised online privacy statement will only apply to data collected subsequent to its effective date. Any revisions will be posted at least seven days prior to its effective date.

Use of Non-Personal and Aggregate Information
We may use non-personal and aggregate information to better design our Sites and share with our marketing and advertising agencies.

Tracking Technologies

The DTNA Sites use cookies to personalize and control access to content, to provide social media features and to analyze our website traffic. Cookies are small text files that can be used by websites to make a user’s experience more efficient. We also share information about your use of our Sites with our social media and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. You consent to our cookies if you continue to use our websites.

The law states that we can store cookies on your device if they are strictly necessary for the operation of our Sites. For all other types of cookies we need your permission.

The DTNA Sites use different types of cookies. Some cookies are placed by third party services that appear on our pages.

For more information, please refer to our Cookie Policy.

California Supplement to Privacy Statement (California Residents)

Last Updated: February 7th, 2021

This California Supplement to the Privacy Statement supplements the information contained in DTNA’s Privacy Statement above and applies solely to all visitors, users, and others who reside in the States of California (“consumers” or “you”). It also applies to the related online services (the “Services”) that we provide through our Websites (the “Sites”). This Privacy Policy applies solely to the Personal Information (as defined below in Section 1) collected from consumers or users who reside in the State of California (“users,” “consumers” or “you”). The California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”) require certain notice(s) and may provide specific rights to consumers, which are detailed below. Any terms defined in the CCPA or CPRA have the same meaning as used in those statutes when used in this notice.

By using DTNA’s Sites and/or the Services, and providing us with Personal Information you agree to the practices described in this Privacy Policy and the Cookie Policy referenced below and to the updates to these policies posted here from time to time. To make sure you stay informed of all changes, you should check these policies periodically. Updates will be referenced by the “Last Updated” date shown above.

Definition of Personal Information (CCPA and CPRA)
For purposes of this Privacy Policy, except where a different definition is noted, “Personal Information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device.

Personal Information for purposes of this Privacy Policy does not include:

California “Shine the Light” Law/Your California Privacy Rights
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits consumers who are California residents, to request and obtain from us once a year, free of charge, information about the categories of personal information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties’ direct marketing purposes. Our disclosure requirements apply only if we share our consumers’ personal information with third parties for them to directly market their own products to those consumers, instead of assisting us with our own business. If you are a California resident and would like to make such a request, contact us as provided in the “Contact Us“ section below.


Information DTNA Collects
As more fully explained in the Privacy Statement above, DTNA’s Sites collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“ Personal Information”). In particular, DTNA’s Sites have collected the following categories of Personal Information from its users within the last twelve (12) months:


Category A: Identifiers

Examples: A real name, Internet Protocol address, email address, or other similar identifiers.

Collected: YES

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.

Collected: YES

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: NO

In response to a verified consumer request for categories of information collected, we will investigate and provide an individualized response to the consumer, and will not merely refer the consumer to our general practices outlined in this Privacy Policy unless our response would be the same for all consumers and this Privacy Policy discloses all the information that is otherwise required for the response to such a consumer request.


DTNA collects the categories of Personal Information listed above from the following types of sources:

Use of Personal Information

DTNA may use, or disclose the Personal Information it collects for one or more of the following business purposes:


Sharing Personal Information/ Disclosures of Personal Information for a Business or Commercial Purpose
DTNA may disclose your Personal Information to a third party for “business” or “commercial” purposes (as defined under the CCPA). When DTNA discloses Personal Information for a business or commercial purpose, DTNA enters a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

DTNA shares your Personal Information with the following categories of third parties: payment processing companies, third party service providers necessary for providing services requested by you, and companies that manage DTNA’s purchase order website and DTNA brand sites. DTNA also may use or disclose Personal Information it collects for additional business or commercial purposes, which may include the following examples. The examples provided are illustrative and not intended to be exhaustive.

(a) Auditing Interactions with Consumers. For example: monitoring traffic to our Sites, counting ad impressions, and auditing legal and regulatory compliance.

(b) Security. For example, maintaining the safety, security, and integrity of our Sites, products and Services, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators, and responding to law enforcement requests or court orders and to comply with any applicable laws and regulations.

(c) Debugging/Repair. For example, identifying and repairing errors in the functionality of our Sites.

(d) Certain Short-term Uses. For example, ad customization that does not involve or contribute to profiling.

(e) Performing Services. For example, creating, maintaining, customizing and securing your account with us, processing your purchases, transactions, and payments, hosting our Sites, managing databases, performing analyses, and billing, and marketing services.

(f) Internal Research for Tech Development. For example, testing, research, analysis, and product development, including to develop and improve our Sites, products, and Services.

(g) Quality and Safety Maintenance and Verification. For example, improving, upgrading or enhancing our products or Services, and verifying the quality or safety of our Services.

(h) Our affiliates. For example, to perform Services.

(i) Service providers: For example, contractors, agents or sponsors who help us manage or provide our products and Services by, for example: developing or supporting products and features; sending email messages on our behalf; processing payments; fulfilling orders; auditing; processing data or statistics; and serving, customizing or delivering products, Services or marketing. These third party service providers are required to protect Personal Information entrusted to them and not use it for any other purpose than the specific service they are providing on our behalf.

(j) Advertisers, advertising technology companies. For example, to perform analytics companies.

(k) Government regulators. For example, to comply with government laws and requirements.

(l) Our legal advisors and parties involved in a legal process. For example, to prosecute or defend legal actions or comply with laws.

(m) To an entity involved in the sale of our business. For example, in the event of a sale of all or part of DTNA’s business.

(n) Third parties to whom you or your agents authorize us to disclose your Personal Information. For example, to provide products or Services.

(o) Other Commercial Purposes. Examples include: (i) purposes as described to you when collecting your Personal Information: (ii) if you sign up for text messaging, cookies or other tracking devices may be used to personalize your experience: and (iii) to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information we hold is among the assets transferred.

If we decide to collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes we will update this Privacy Policy.

In response to a verified consumer request to know what Personal Information was collected or sold, DTNA will investigate and provide an individualized response to the consumer, which will include the business or commercial purpose for collecting and/or sharing that information. DTNA will not merely refer the consumer to our general practices outlined in this Privacy Policy unless our response would be the same for all consumers and this Privacy Policy discloses all the information that is otherwise required for the response to such a consumer request.

DTNA does not sell your Personal Information to third parties or receive benefits from third parties for sharing Personal Information.

Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights
You have the right to request that DTNA disclose certain information to you about its collection and use of your Personal Information over the past 12 months. Once DTNA receives and confirms your verifiable consumer request, DTNA will disclose to you:

Deletion Request Rights
You have the right to request that DTNA delete any of your Personal Information that DTNA has collected and retained, subject to certain exceptions. Once DTNA receives and confirms your verifiable consumer request, DTNA will delete (and direct our service providers to delete) your Personal Information from its records, unless an exception applies.

DTNA may deny your deletion request if retaining the information is necessary for DTNA or its service provider(s) to:

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message to DTNAprivacy@daimlertruck.com. You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

The verifiable consumer request must provide sufficient information that allows DTNA to reasonably verify you are the person about whom DTNA collected Personal Information or an authorized representative. This means that in making a request you may be required to: provide your email and phone number, customer information, and/or account sign-up authentication or other information needed to verify your identity depending on the sensitivity of the Personal Information that is the subject of the request.

DTNA cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. If DTNA is unable to verify your identity, we reserve the right to deny the request. Making a verifiable consumer request does not require you to create an account with DTNA. DTNA will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

If you choose to use an authorized agent to submit a request to know or a request to delete your information, DTNA may require that you: (1) provide the authorized agent written permission to do so; and (2) verify your own identity directly with DTNA. DTNA will not require these steps if we have received proof that you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465. DTNA may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. DTNA may also deny a request from an agent that does not meet the requirements for authorized agents under the CCPA.

Once DTNA has verified your identity (and your authorized agent, as applicable), DTNA will respond to your request as appropriate. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. If we are unable to complete your request in whole or in part, we will let you know why.

Response Timing and Format
DTNA makes reasonable efforts to respond to a verifiable consumer request within forty-five (45) days of its receipt. If DTNA requires more time (up to ninety (90) days), DTNA will inform you of the reason and extension period in writing. DTNA will deliver its written response by mail or electronically, at your option. Any disclosures DTNA provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. DTNA’s response will also explain the reasons DTNA cannot comply with a request, if applicable. For data portability requests, DTNA will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

DTNA does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If DTNA determines that the request warrants a fee, DTNA will tell you why it made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

However, DTNA may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive DTNA offers will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to DTNA’s California Privacy Notice
DTNA reserves the right to amend this privacy notice at its discretion and at any time. When DTNA makes changes to this privacy notice, it will post the updated notice on DTNA’s Sites and update the notice’s effective date. Your continued use of DTNA’s Sites following the posting of changes constitutes your acceptance of such changes.

Contact Information
If you have any questions or comments about this Privacy Statement, the ways in which DTNA collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact DTNA.

Email: DTNAprivacy@daimlertruck.com
Phone: 1-800-331-0807
Mailing Address:
Daimler Truck North America LLC
4555 N. Channel Ave
Portland, OR 97217